(Text in italics should be customized for your use.)

_______________________________________________________________________

Dr. Stephen Beam
Milk and Dairy Food Safety Branch
1220 N Street, Suite A-170
Sacramento, California 95814

December 12, 2008

Dear Dr. Beam,

As interested persons, we respectfully request you adopt the temporary standard for gelato submitted by Gelateria Naia on August 21, 2008, and we now submit testimony to that end.

You asked us whether the product proposed for a temporary standard qualifies for that standard.

Yes. In our experience, when we purchase gelato we expect a product that is lower fat than ice-cream, with low overrun, and made from all-natural ingredients. This is precisely what the submitted temporary standard describes as “gelato”.

You also asked for existing definitions and standards for comparable products, if they exist.

We are confused by products called “gelato” which are merely “ice cream” as defined by California Food and Agriculture Code Section 36861. The submitted temporary standard for “gelato” is completely different from the definition of “ice cream.” This reduces our confusion between “ice cream” and “gelato”.

Please adopt this temporary standard for gelato.

Yours sincerely,

Chris Tan